Mail Stop: 3628
                                                            September 13, 2019

David Rands
Chief Financial Officer
Volkswagen Auto Lease/Loan Underwritten Funding, LLC
2200 Ferdinand Porsche Drive
Hernson, Virginia 20171

       Re:    Volkswagen Auto Lease/Loan Underwritten Funding, LLC
              Registration Statement on Form SF-3
              Filed August 23, 2019
              File No. 333-233424

Dear Mr. Rands:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

The Sponsor, page 46

   1. Please tell us whether ongoing civil litigation relating to TDI diesel
engines, in which
      VW Credit Inc., is involved, is material to the securities that you are
registering. If so,
      please revise this section and your disclosure on legal proceedings as
appropriate or
      confirm that you will provide current descriptions of any pending
litigation at the time of
      each offering pursuant to Items 1104 and 1117 of Regulation AB.

Description of the Transaction Documents   Requests to Repurchase and Dispute
Resolution,
page 90

   2. We note your disclosure that "[i]f more than one investors directs the
indenture trustee in
      connection with a request to purchase, the indenture trustee will act at
the direction of the
      investors holding a majority of the outstanding note balance of the notes
held by such
      directing investors." It is unclear to us that this would allow any
investor to utilize the
 David Rands
Volkswagen Auto Lease/Loan Underwritten Funding, LLC
September 13, 2019
Page 2

       dispute resolution proceeding. Please tell us why it is appropriate to
impose this
       limitation on investors before they are able to utilize the dispute
resolution provision.
       Refer to Section V.B.3(a)(3) of the 2014 Regulation AB II Adopting
Release.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Kayla Roberts at (202) 551-3490 or me at (202) 551-3850
with any
questions.


                                                             Sincerely,

                                                             /s/ Katherine Hsu

                                                             Katherine Hsu
                                                             Office Chief
                                                             Office of
Structured Finance

cc:    Stuart M. Litwin, Mayer Brown LLP
       Kevin McDonald, VW Credit, Inc.